| Development | Date and status | Buyer exposure | Action in the estimate |
|---|---|---|---|
| EPA Technology Transitions reconsideration | Final rule published 26 May 2026; effective 27 July 2026 | Certain legacy light-commercial AC/heat-pump inventory | The installation deadline was removed where all specified components were manufactured/imported before 1 January 2025; retain component evidence. Final rule |
| VRF transition | EPA lists a 700 GWP threshold and 1 January 2027 installation date, with conditions | Field-assembled VRF projects | Check pre-2026 component dates; a separate qualifying pre-5 October 2023 permit route extends to 1 January 2028. Read all conditions. EPA sector table and footnote 7 |
| HFC leak-repair obligations | Applicable requirements began 1 January 2026 | Covered appliances with charge ≥15 lb and relevant HFC/substitute conditions | Do not apply this universally: residential/light-commercial AC and heat pumps are excluded from this leak-repair provision. January 2026 fact sheet |
| A2L installation code coordination | Ongoing adoption/amendment issue, not one national switch date | Equipment using mildly flammable refrigerants | Confirm the adopted code and local amendments with the authority having jurisdiction. ICC transition resources |
| Commercial unitary efficiency standards | DOE confirms 1 January 2029 compliance for the specified amended standards | Covered air-cooled equipment with cooling capacity ≥65,000 Btu/h | Track equipment class and applicable efficiency metric; do not apply one threshold to every HVAC product. DOE programme page |
“Upcoming” refers to future compliance dates in the cited sources, not an assumption that a proposal has become law.
Sources cited on this page
- Final rulefederalregister.gov
- EPA sector table and footnote 7epa.gov
- January 2026 fact sheetepa.gov
- ICC transition resourcesiccsafe.org
- DOE programme pageenergy.gov